SAFEX Newsletter No.35 - EU-Excert

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SAFEX Newsletter No.35, 4 th Qtr. 2010 20 classification testing procedure be conducted in order to classify the new composition. Before doing any work a risk assessment was conducted as a part of work and safety procedure. The incident occurred during the production of the testing sample. No violation of safety and work procedures was found. The current position is that we are preparing a fully automatic sample line in order to conduct the hazard classification procedures. We will also try to reproduce an ignition/deflagration/explosion in order to understand the mechanism of this particular event. I appreciate and respect both Maurice and Andy’s comments and thank them for their interest. Safety Snippets Lone-working: Feedback on Members’ comments In October we approached SAFEX members on behalf of Maurice Bourgeois (GD-OTS Canada) for information about various countries’ regulations regarding lone-working with explosives. Typical questions asked include the explosives handling operations in which lone workers are permitted or not permitted. As with the similar request on the use of a “lone worker alarm” in a production facility we posed previously (see SAFEX Newsletter No.30, 3 rd Quarter 2009 ), we had a gratifying response from the following members of the SAFEX community: Frank Barker (Expert Panel); Massimo Berti (Simmel Difesa); Jorge Carbajal (Austin Bacis); Ashley Haslett (Ulster Industrial Explosives); Ernest Hodgson (Rheinmetall Denel Munition); Claude Modoux (Poudrerie d’Aubonne); Helen Muller (Dyno Nobel); Erik Nilsson (KCEM); Takaaki Torikai (Kayaku Japan); Mervyn Traut (Expert Panel); John Bennett (Orica MEA); Jean-Yves Canihac (Groupe EPC); Susan Flanagan (IME); Martin Held (Austin International); Gunter Kleinrath (Schaffler); Lisa Molochkova, (Novosibirsk Iskra); Dawie Mynhardt (BME); Lon Santis (IME); Stuart Tough (NIXT); Dave White (EPC-UK) Maurice found the responses very helpful and asked me to convey his appreciation to all those who responded. He kindly put together this summary using the responses he received: It is clear regulators in many countries have not addressed this issue. The reason may be that a list of explosives related tasks which can be done in “workalone mode could be never-ending. In my view working with primary explosives and exposed pyrotechnic powders is similar to certain situations in the electrical industry. An electrician working on live circuits or on equipment and processes requiring two or more workers in emergency situations may by law not work alone. Someone needs to be around to intervene if the electrician needs help. This is similar to working at heights or in enclosed spaces where workers are also prohibited from working alone. To make a judgment about permitting lone-working, companies typically rely on risk assessment and rightfully so. However, unless the assessment focuses on the implications of lone-working, a superficial conclusion may be: “if the risk is acceptable in normal operations it should be acceptable for lone-working”. Perhaps lone-working should be the subject of a SAFEX Good Practice Guide. The importance of such a Guide is highlighted by the competitive nature of today’s business environment. In this climate companies, including those in the explosives industry, are obliged to reduce “unnecessary” personnel in an attempt to cut costs. Perhaps we should start by defining what Loneworking is. The Dyno Nobel standard which Helen Muller kindly shared with me serves as a useful starting point. I have taken the liberty to modify it to read as follows: A worker works alone when he cannot be: • seen; or • heard without an electric sound device; or • visited frequently during the course of his work by co-workers or supervisor; and/or • helped immediately (within 15 seconds) in an emergency. This may entail someone nearby having to pull him out of harm’s way or assist him with an emergency task which requires two or more workers.
SAFEX Newsletter No.35, 4 th Qtr. 2010 21 In an attempt to stimulate further debate, I highlight some of the issues that are apparent from the inputs received: a. As mentioned by Lon Santis of IME, loneworking mode should be avoided when explosives are involved and be used as a last resort when it can’t be avoided. Sometimes more effort is put into trying to justify lone-working than finding an alternative solution. b. Risk analysis should be reviewed with a focus on lone-working (especially in dealing with unusual situations) c. Lone working should be prohibited for tasks which represent higher inherent risks (these are high risk tasks which may have become lower risk tasks with mitigating measures) . Such tasks included destruction of explosives and working with exposed sensitive primary explosives or pyrotechnic powders. In these circumstances there are many possible causes of mishap and a second operator located at a safe distance is necessary to lend a helping hand, administer first aid or initiate an emergency. d. Lone working should not be permitted in processes where • a lone operator cannot cope with emergency situations that can degenerate into a catastrophe or expose the operator to injury; or • unusual situations identified after HAZOP studies; or • unforeseen incidents not identified in HAZOP studies and indicative of equipment or process hazards that are not fully understood. Such processes should not be operated in work alone mode. e. Lone work mode should be analyzed on a personal basis: Health background check of the lone worker, safety record, training on the job, experience in that particular task, etc. f. Lone work mode should be analyzed for past incidents for the task or equipment, for unusual events, how they are recognized and dealt with. g. As per an INRS document on this topic, studies indicate that the accident frequency is higher in a lone working environment. Reasons cited include boredom (nobody around to talk to); temerity and a tendency to take shortcuts because there is nobody around to see what is going on. In these situations more frequent visits by the supervisor are necessary. For these reasons personal background checks on the trustworthiness of the individual are so important. h. Obviously man-down devices with GPS is available and should be considered i. A proper communication system with contact at least every half hour (and reporting of any travelling to other areas or the whereabouts on real time basis) should be established and a log kept by the person to whom the worker reports. If no call is received that person must try to contact the worker at the given time indicated in the log. j. For some workstations, instructions can prohibit certain operations to be performed alone in which case a second operator or a helping hand is called in. k. Sometimes a process has to commence 1 hour before the normal shift. Such start-ups usually require more operator interventions and hence more human errors can occur. Management should ask itself whether work alone mode is worth it in this situation. These are some thoughts on the subject and I look forward to any comments from Newsletter readers Gun Powder Manufacturer Fined $1.2 Million Following Deadly Explosion This article appeared on 27 October 2010 in the OH&S Magazine which is an online publication of Occupational Health & Safety, an 1105 Media Inc. magazine, www.ohsonline.com. It is reproduced in its entirety with the kind permission of the Editor, Jerry Laws. We thank Jerry for allowing us to publish his article in this Newsletter. You can view the original article at http://ohsonline.com/articles/2010/10/27/gun-powder-manufacturer-fined-12-millionfollowing-deadly-explosion.aspx?admgarea=ht.FireSafety OSHA has issued 54 workplace safety and health citations with penalties totalling $1.2 million to gun powder substitute manufacturer Black Mag LLC, following an investigation into the causes of a deadly explosion in May at the company's worksite in Colebrook, N.H. The explosion took the lives of two workers who had been on the job for only a month. "The fines levied here pale in comparison to the value of the two lives lost," said Secretary of Labor Hilda L. Solis. "Nonetheless, this was a tragedy that easily could have been prevented had the employer valued the health and safety of its employees. Employers should not sacrifice their workers' lives for a profit, and no one should be injured or killed for a pay check." On May 14, two workers and a
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